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OSHA 1919.74

Annual derrick examination requirements

Subpart H

13 Questions & Answers
8 Interpretations

Questions & Answers

Under 1919.74(a), who may perform the annual examination of a derrick in a year when no quadrennial unit proof test is required?

Under 1919.74(a), the annual examination must be carried out by an accredited person or that accredited person's authorized representative 1919.74(a).

  • This text is explicit: the person doing the inspection must either be the accredited person or someone the accredited person authorizes to act on their behalf.
  • If you need details about what qualifications "accredited person" or "authorized representative" should have in maritime contexts, see the OSHA interpretation discussing competent/accredited person procedures Competent person accreditation procedures (Apr. 26, 1977).

Under 1919.74(a), when must the annual derrick examination be completed?

Under 1919.74(a), the annual examination must be made not later than the anniversary date of the quadrennial certification 1919.74(a).

  • That means the inspection must occur on or before that anniversary date each year in which a quadrennial unit proof test is not required.
  • If you need to confirm what to record or other timing details, follow the requirements in 1919.71(d) as referenced by 1919.74(a).

Under 1919.74(a), what happens in years when a quadrennial unit proof test is required—do you still need an annual examination?

Under 1919.74(a), in years when a quadrennial unit proof test is required, the specific annual examination described in that paragraph is not required because 1919.74(a) applies only "in any year in which no quadrennial unit proof test is required" 1919.74(a).

  • In practice, the quadrennial unit proof test performed in that scheduled year serves as the required periodic evaluation for that cycle; follow the quadrennial test requirements elsewhere in Part 1919.
  • For procedural overlap and recordkeeping, ensure compliance with the related requirements in 1919.71 and especially 1919.71(d).

Under 1919.74(a), what does it mean that the annual examination "shall conform in all applicable respect with 1919.71(d)"?

Under 1919.74(a), it means the annual examination must follow the procedures, scope, and any applicable record or certification steps described in 1919.71(d).

  • Practically, you must read 1919.71(d) and apply those parts that are relevant to an annual inspection (for example, any inspection protocol, acceptance criteria, and documentation requirements contained there).
  • Because 1919.74(a) cross-references 1919.71(d), you should treat 1919.71(d) as mandatory for the annual exam to the extent those provisions apply.

Under 1919.74(a), can the accredited person delegate the annual derrick examination to an on-site employee or manager as an "authorized representative"?

Under 1919.74(a), yes—the accredited person may have an authorized representative carry out the annual examination, provided that representative is authorized by the accredited person and capable of performing the duties 1919.74(a).

  • The standard text allows delegation but does not spell out specific credentialing for the authorized representative; therefore the accredited person should ensure the representative is qualified to perform the inspection and follow the applicable parts of 1919.71(d).
  • For background on employer responsibility for assigning competent or accredited persons in maritime settings, see Competent person accreditation procedures (Apr. 26, 1977).

Under 1919.74(a), what is meant by an "accredited person" and who determines accreditation?

Under 1919.74(a), an "accredited person" is the person recognized to perform the required examinations, and the accreditation process and recognition are governed by the procedures in Part 1919 and related OSHA accreditation guidance 1919.

  • OSHA has historically discussed accreditation and competent-person recognition in maritime guidance; see Competent person accreditation procedures (Apr. 26, 1977) for context on how accreditation/recognition and the employer's role have been treated in maritime standards.
  • Because Part 1919 sets the overall framework for gear certification, consult 1919.71 and 1919.74(a) to confirm specific accreditation requirements that apply at your operation.

Under 1919.74(a), are there recordkeeping or certification steps required after the annual derrick examination?

Under 1919.74(a), any recordkeeping or certification steps required for the annual examination are those contained in 1919.71(d), because 1919.74(a) requires the annual exam to conform with that paragraph.

  • To know exactly what must be recorded or certified after the annual exam, follow the instructions and documentation requirements in 1919.71(d).
  • If you are unsure how to apply those recordkeeping requirements at your workplace, consult your accredited person or the employer's safety management and retain the documentation as required by 1919.71(d).

Under 1919.74(a), what should an employer do if no accredited person is available to perform the annual examination before the anniversary date?

Under 1919.74(a), the employer must ensure the annual examination is completed by an accredited person or that person's authorized representative on or before the anniversary date; if no accredited person is available the employer must take steps to obtain an accredited person or an authorized representative so the requirement is met 1919.74(a).

  • The regulation places the onus on the employer to have the required accredited person or authorized representative available; if necessary, arrange for an accredited third party or have the accredited person designate a qualified authorized representative who can perform the exam.
  • For guidance on how accreditation and assignment of competent persons have been handled in maritime standards, see Competent person accreditation procedures (Apr. 26, 1977).

Under 1919.74(a), does the annual examination have to follow the exact same tests as a quadrennial unit proof test?

Under 1919.74(a), the annual examination must conform in all applicable respects to 1919.71(d), but it is distinct from the quadrennial unit proof test that is performed in its scheduled years 1919.74(a).

  • In plain terms, follow the inspection scope and procedures in 1919.71(d) for annual exams, but recognize that the quadrennial proof test is a separate, more comprehensive test conducted on its scheduled cycle.
  • If you need to confirm which specific tests are required for a quadrennial proof test versus an annual examination, review the quadrennial testing requirements elsewhere in Part 1919 and consult your accredited person.

Under 1919.74(a), can the accredited person be an employee of the employer that owns the derrick, or must they be independent?

Under 1919.74(a), the text does not specify that the accredited person must be independent or external; it simply requires the examination be carried out by an accredited person or that person's authorized representative 1919.74(a).

  • Whether the accredited person can be an employee depends on the accreditation process and any conflict-of-interest rules tied to accreditation under Part 1919; consult 1919 and the accreditation guidance in your program.
  • For historical context on how competent/accredited persons have been designated in maritime settings, see Competent person accreditation procedures (Apr. 26, 1977).

Under 1919.74(a), if deficiencies are found during the annual examination, does the section tell you what to do next?

Under 1919.74(a), the section itself does not list remedial steps, but it requires the annual exam to conform with 1919.71(d), so any corrective-action requirements in that paragraph apply.

  • In other words, follow the provisions for handling deficiencies (including any removal-from-service, repair, re-inspection, or documentation steps) that are specified in 1919.71(d).
  • If you cannot find specific instructions there or need help interpreting them for your situation, consult your accredited person or the employer's safety management for corrective-action procedures consistent with Part 1919.

Under 1919.74(a), how strictly must the anniversary date of the quadrennial certification be observed for the annual examination?

Under 1919.74(a), the annual examination "shall be made not later than the anniversary date of the quadrennial certification," so the examination must be completed on or before that anniversary date each year when no quadrennial test is required 1919.74(a).

  • That language means you cannot delay the required annual exam past the anniversary; plan inspections so that they occur by that date.
  • For any documentation or certification of the exam you perform, follow the related provisions in 1919.71(d).

Under 1919.74(a), where can I find the full set of requirements that an annual derrick examination must follow?

Under 1919.74(a), the annual examination must conform with 1919.71(d), so the full set of applicable requirements is found by reading 1919.71(d) together with Part 1919.